Lee Hsien Loong v Leong Sze Hian 69 [2021] SGHC 66 The second reason why I am reluctant to directly apply Jameel to the present facts is because the reasoning in that decision centres in very large part on the English Court’s concern with forum shopping. This is evident from the face of Jameel itself at [70]: If we were considering an application to set aside permission to serve these proceedings out of the jurisdiction we would allow that application on the basis that the five publications that had taken place in this jurisdiction did not, individually or collectively, amount to a real and substantial tort. Jurisdiction is no longer in issue, but, subject to the effect of the claim for an injunction that we have yet to consider, we consider for precisely the same reason that it would not be right to permit this action to proceed. It would be an abuse of process to continue to commit the resources of the English court, including substantial judge and possibly jury time, to an action where so little is now seen to be at stake. Normally where a small claim is brought, it will be dealt with by a proportionate small claims procedure. Such a course is not available in an action for defamation where, although the claim is small, the issues are complex and subject to special procedure under the CPR. As noted in my earlier decision in these proceedings in SUM 428, Jameel was really a case concerned with private international law principles. The defendant in Jameel was, after all, a US publisher of a newspaper that had published an allegedly defamatory article on the internet, and the issue which arose was whether the defamation claim could be struck out if no significant publication had occurred in England. Requiring that a real and substantial tort be “committed within the jurisdiction” (Jameel at [50]) appears to go towards establishing a connexion with English jurisdiction in the first place. This is further evident from the reference at [70] of Jameel that it would be an abuse of process “to continue to commit the resources of the English court, including substantial judge and possibly jury time, to an action where so little is now seen to be at stake”. The reference to “so little … at stake” must be understood by reference to the fact that only five persons within English jurisdiction had 37